The CFPB Effectively Monitors Consumer Complaints but Can Enhance Certain Processes

2024-MO-C-016 1 of 25

Audit Report

2024-MO-C-016

June 24, 2024

Consumer Financial Protection Bureau

The CFPB Effectively Monitors Consumer

Complaints but Can Enhance Certain

Processes

2024-MO-C-016 2 of 25

Executive Summary, 2024-MO-C-016, June 24, 2024

The CFPB Effectively Monitors Consumer Complaints but Can Enhance

Certain Processes

Findings

The Consumer Financial Protection Bureau’s Office of Consumer Response

generally followed its processes for reviewing and monitoring the timeliness,

accuracy, and completeness of company responses to consumer complaints.

For each year we reviewed, Consumer Response (1) used a risk-based

approach to select companies for review and prioritized companies with the

most consumer complaints, (2) followed its processes for sampling consumer

complaints from selected companies and conducting quality assurance

reviews, and (3) met its annual Government Performance and Results Act

Modernization Act performance goal to review the response performance of

at least 85 percent of the companies with more than 250 annual complaints.

Consumer complaint volume increased significantly from 2019 to 2022, and

the risk-based processes used by Consumer Response enabled its company

monitoring team to scale up its review of company responses.

Consumer Response’s company monitoring teams generally followed the

office’s procedures for documenting their review of company responses to

consumer complaints in assessment questionnaires; however, 6.5 percent of

the assessment questionnaires completed from 2019 through 2022 had

incomplete determination finding fields. Consumer Response can strengthen

controls to ensure that all required fields are consistently completed.

Consumer Response has piloted the distribution to companies of

discretionary company-specific reports that provide information about their

complaint handling and response performance. Consumer Response’s pilot

process for issuing company-specific reports lacked measurable objectives, a

completion date, and formal written guidance. In addition, Consumer

Response did not develop a procedure to periodically evaluate the pilot

process. To effectively measure the pilot process’s success, Consumer

Response should finalize objectives and conduct periodic monitoring;

developing formal guidance will help Consumer Response establish a

repeatable process.

Recommendations

This report contains three recommendations designed to enhance Consumer

Response’s processes for issuing company-specific reports on response

performance. In its response to our draft report, Consumer Response

concurs with our recommendations and outlines actions to address them.

We will follow up to ensure that the recommendations are fully addressed.

Purpose

We conducted this audit to

assess the effectiveness of

Consumer Response’s processes

for reviewing and monitoring the

timeliness, accuracy, and

completeness of company

responses to consumer

complaints in accordance with its

established directives and

procedures. To accomplish our

objective, we reviewed

Consumer Response’s directives

and procedures for reviewing

and monitoring company

responses to consumer

complaints.

Background

Collecting, investigating, and

monitoring consumer complaints

about consumer financial

products and services is a

primary function of the CFPB. To

address a statutory mandate,

Consumer Response monitors

consumer complaints to

companies. Consumer Response

company monitoring teams

review company responses and

assess whether those responses

timely, accurately, and

completely address a complaint.

2024-MO-C-016 3 of 25

Recommendations, 2024-MO-C-016, June 24, 2024

The CFPB Effectively Monitors Consumer Complaints but Can Enhance

Certain Processes

Finding 1: Consumer Response Generally Followed Its Processes for Reviewing and Monitoring Company

Responses to Consumer Complaints

Number

Recommendation

Responsible office

No recommendations.

Finding 2: Consumer Response Should Ensure Consistent Documentation of Company Response

Performance

Number

Recommendation

Responsible office

No recommendations.

Finding 3: Consumer Response Can Strengthen Its Processes for Issuing Company-Specific Reports on

Response Performance

Number

Recommendation

Responsible office

Finalize measurable objectives and establish a completion date for the

company-specific reports pilot process.

Division of Consumer

Response and Education

Establish written guidance for issuing company-specific reports.

Division of Consumer

Response and Education

Periodically monitor the company-specific reports pilot process to measure its

effectiveness in improving company responsiveness.

Division of Consumer

Response and Education

2024-MO-C-016 4 of 25

MEMORANDUM

DATE: June 24, 2024

TO: Christopher Johnson

Associate Director, Division of Consumer Response and Education

Consumer Financial Protection Bureau

FROM: Michael VanHuysen

Associate Inspector General for Audits and Evaluations

SUBJECT: OIG Report 2024-MO-C-016: The CFPB Effectively Monitors Consumer Complaints but Can

Enhance Certain Processes

We have completed our report on the subject audit. We conducted this audit to assess the effectiveness

of the Consumer Financial Protection Bureau Office of Consumer Response’s processes for reviewing and

monitoring the timeliness, accuracy, and completeness of company responses to consumer complaints in

accordance with its established directives and procedures.

We provided you with a draft of our report for review and comment. In your response, you concur with

our recommendations and outline actions that have been or will be taken to address them. We have

included your response as appendix B to our report.

We appreciate the cooperation that we received from Consumer Response. Please contact me if you

would like to discuss this report or any related issues.

cc: Jan Singelmann

Darian Dorsey

Adam Martinez

Jean Chang

Marianne Roth

Richard Austin

Ashley Adair

2024-MO-C-016 5 of 25

Contents

Introduction 6

Objective 6

Background 6

Office of Consumer Response 6

Consumer Complaint Process 6

Consumer Complaint Volume, 2019–2022 7

Key Processes and Directives for Reviewing and Monitoring Consumer Complaints 8

Finding 1: Consumer Response Generally Followed Its Processes for Reviewing and

Monitoring Company Responses to Consumer Complaints 11

Management Response 12

Finding 2: Consumer Response Should Ensure Consistent Documentation of Company

Response Performance 13

Consumer Response Should Develop System Controls for All Required Fields 13

Management Actions 14

Management Response 14

Finding 3: Consumer Response Can Strengthen Its Processes for Issuing Company-

Specific Reports on Response Performance 15

Consumer Response Should Finalize Measurable Objectives, Establish Formal Written

Guidance, and Periodically Evaluate Its Company-Specific Reports Issuance Pilot Process 15

Recommendations 16

Management Response 16

OIG Comment 17

Appendix A: Scope and Methodology 18

Appendix B: Management Response 20

Abbreviations 24

2024-MO-C-016 6 of 25

Introduction

Objective

The objective of this audit was to assess the effectiveness of the Consumer Financial Protection Bureau

Office of Consumer Response’s processes for reviewing and monitoring the timeliness, accuracy, and

completeness of company responses to consumer complaints in accordance with its established

directives and procedures. Our scope focused on Consumer Response’s processes for reviewing and

monitoring company responses to consumer complaints and issuing company-specific reports about their

response performance. We reviewed consumer complaints and company responses submitted from

January 2019 through December 2022.

To accomplish our objective, we reviewed Consumer Response’s directives and procedures for reviewing

and monitoring company responses to consumer complaints. We interviewed Consumer Response

officials to obtain an understanding of the office’s company monitoring processes. We also reviewed and

analyzed Consumer Response’s company monitoring data from 2019 to 2022. Additional details on our

scope and methodology are in appendix A.

Background

In accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act, collecting,

investigating, and responding to consumer complaints is a primary function of the CFPB. Under the

authority granted by the Dodd-Frank Act, the CFPB began its Consumer Response operations in 2011, the

same year the agency was established. Consumer Response receives complaints from consumers about

the challenges they face in the financial marketplace, alerts companies to those concerns, and monitors

company responses. Additionally, in accordance with its reporting requirements, the CFPB publishes a

Consumer Response annual report, which details the complaints received from January 1 through

December 31 of the prior year.

Office of Consumer Response

Consumer Response is an office within the CFPB’s Division of Consumer Response and Education.

Consumer Response analyzes complaint data to inform the CFPB’s data-driven approach to regulating

consumer financial products and services, identifying trends, and detecting possible instances of

consumer harm. Consumer Response’s Investigations section manages the consumer complaint review

process and monitors company responses to consumer complaints.

Consumer Complaint Process

The consumer complaint process begins with the CFPB receiving a complaint from a consumer through its

website, by telephone, by mail, or by referral. Complaints include information provided by the consumer:

The report analyzes information about complaint numbers and complaint types and includes information about complaint

resolution.

2024-MO-C-016 7 of 25

the consumer financial product or service concerned, the category that best describes the issue, and the

subject company, as well as a complaint narrative describing the issue and the desired resolution. Once

received, the complaint proceeds through several steps designed to help the consumer receive a timely

response to their complaint (figure 1).

Figure 1. Consumer Complaint Process

Source: The CFPB’s 2022 Consumer Response annual report.

When responding through the secure portal, companies select a response category; the substantive

response choices are in progress, closed with explanation, closed with monetary relief, and closed with

non-monetary relief.

The CFPB’s documented expectations for company responses involve three elements: (1) timeliness—the

company should provide a response within 15 calendar days of the complaint being sent to the

company;

(2) accuracy—the company selects the most appropriate response category; and

(3) completeness—the company must address every concern raised by the consumer and provide any

relevant documentation.

The CFPB publishes the subject and date of the complaint and the company’s response category

selection, omitting any personal information, in the Consumer Complaint Database on its website.

Complaints are published after the company responds or within 15 days of the CFPB sending a complaint

to the company, whichever comes first. If the complainant consents, the CFPB also publishes the

complaint narrative after removing the consumer’s personal information.

Within 60 days from the date the company responds, the consumer can provide feedback on the

response by completing an optional survey. This survey gives the consumer the option to provide both

positive and constructive feedback. This feedback is made available to the company through the secure

portal.

Consumer Complaint Volume, 2019–2022

The number of consumer complaints submitted to the CFPB has grown significantly since 2019 (figure 2).

Complaints increased by 53.9 percent from 2019 to 2020, by 83.3 percent from 2020 to 2021, and by

29.5 percent from 2021 to 2022. Complaints related to credit or consumer reporting accounted for much

Administrative responses that companies may select include alerted CFPB, duplicate CFPB complaint reported, incorrect

company, and sent to regulator.

If a complaint cannot be closed within this time frame, the company is responsible for providing an interim explanation to the

consumer and to the CFPB and a final response within 60 calendar days of the complaint being sent to the company.

2024-MO-C-016 8 of 25

of this growth—44 percent of the total complaints received by the CFPB in 2019 (154,500 complaints),

59 percent in 2020 (319,300 complaints), 71 percent in 2021 (710,300 complaints), and 76 percent in

2022 (978,900 complaints).

Figure 2. Consumer Complaint Volume, 2019–2022

Source: CFPB annual reports to Congress, 2019 to 2022.

Key Processes and Directives for Reviewing and Monitoring

Consumer Complaints

To assess whether companies provide consumers with timely, accurate, and complete responses to

complaints, company monitoring teams in Consumer Response’s Investigations section review company

responses. Consumer Response uses the following key processes and directives to review and monitor

company responses to consumer complaints:

• Company review schedule development. According to Consumer Response’s Company

Monitoring Directive, the Investigations section uses a risk-based approach to selecting

companies for review and creating a company review schedule. Specifically, the Investigations

section prioritizes reviewing companies that received at least 200 annual complaints. The

Investigations section creates its company review schedule by analyzing company complaint data

and identifying companies for review within its internal complaint monitoring system.

2024-MO-C-016 9 of 25

• Government Performance and Results Act Modernization Act performance goal.

In 2021 and

2022, the Investigations section established a Government Performance and Results Act

Modernization Act, known as GPRA, performance goal to review the response performance of at

least 85 percent of the companies with more than 250 annual complaints.

• Sampling company responses. After companies are identified and added to the company review

schedule, the Investigations section generates a random sample of consumer complaints to be

reviewed by company monitoring teams. According to the Company Monitoring Directive, the

number of total complaints selected for a random sample depends on a preidentified confidence

level and margin of error.

• Reviewing company responses. Company monitoring teams review components of the sampled

consumer complaints to assess the timeliness, accuracy, and completeness of the company

responses. Company monitoring teams use an assessment questionnaire within Consumer

Response’s internal complaint management system to document these reviews. Assessment

questionnaires consist of questions related to the timeliness, accuracy, and completeness of

company responses.

• Quality Assurance (QA) reviews. According to Consumer Response’s Investigations Quality

Assurance Directive, the Investigations section has a QA team that selects and reviews a random

sample of assessment questionnaires completed by company monitoring teams from the

preceding month to ensure that they reflect comprehensive and accurate analyses and follow

applicable procedures.

• Issuing reports to companies about response performance. Consumer Response initiated a

discretionary pilot process in 2021 to share company-specific reports on complaint handling and

response performance with a limited number of companies. This pilot process is not required by

law. Consumer Response compiles the results of several reviews of a single company into a

company-specific report, which is then shared directly with that company to help compliance and

complaint handling personnel better understand their complaint response performance history.

The CFPB issues company-specific reports as part of the company monitoring program. Consumer

Response informed us that its ability to issue these reports depends on various factors, such as

staffing levels, leadership policy priorities, and other factors external to the company monitoring

program.

In 2021 and 2022, Consumer Response followed informal guiding principles when

determining which companies would receive the reports.

Consumer Response officials informed

us that in 2023, subsequent to our fieldwork phase, their guiding principles evolved to include

The Government Performance and Results Act Modernization Act, enacted in 2010, provides the foundation by which federal

agencies are held accountable for establishing management processes and setting performance goals and objectives.

The Investigations section’s GPRA performance goal was 82 percent in 2019 and 83 percent in 2020.

Consumer Response uses a 95 percent confidence level with a 5 percent margin of error to select from a company’s population

of consumer complaints over a given period. For example, if a company received 10,000 complaints in a given period, Consumer

Response would select approximately 370 complaints to review.

For example, the number of Consumer Response staff members decreased over the last 5 years—from 167 in 2018 to 125 in

2023.

Consumer Response’s informal guiding principles for determining which companies received company-specific reports in 2021

and 2022 included, for example, (1) companies with the most significant complaint volume, (2) companies that Consumer

Response had previously reviewed, and (3) depository institutions with greater than $10 billion in assets.

2024-MO-C-016 10 of 25

distributing the reports to nondepository institutions and prioritizing sharing the reports with

companies with lower response performance scores.

2024-MO-C-016 11 of 25

Finding 1: Consumer Response Generally

Followed Its Processes for Reviewing and

Monitoring Company Responses to

Consumer Complaints

We found that Consumer Response generally followed its processes for reviewing and monitoring

company responses to consumer complaints.

Consumer Response used a risk-based approach to select

companies for review and followed its processes for creating company review schedules. In addition, we

found that Consumer Response met its annual GPRA performance goal for company response analysis

during our review period. Further, Consumer Response followed procedures for sampling company

responses to consumer complaints for review and conducting QA reviews of the company monitoring

teams’ assessment questionnaires.

Consumer complaint volume increased significantly from 2019 through 2022, and following the

applicable processes enabled the company monitoring teams to scale up their review of company

responses. Specifically, the number of companies with 250 or more annual complaints that Consumer

Response reviewed increased each year from 2019 through 2022.

Table 1. Select Consumer Response Processes for Monitoring Company Responses and Actions Taken to

Follow Them

Select Consumer Response processes

Actions taken by Consumer Response

Company review schedule development

According to Consumer Response’s Company Monitoring

Directive, Consumer Response selects companies for

review and creates a company review schedule.

Consumer Response prioritizes selecting companies that

received at least 200 annual complaints.

We reviewed company review schedules and company

complaint data from 2019 through 2022 and found that

Consumer Response generally followed its processes

for selecting companies for review and creating

company review schedules.

We found that companies

that received 200 or more annual complaints were

prioritized and included in the company review

schedules.

For the purposes of this finding, we used the term generally to reflect that we found instances of an immaterial deviation from

a Consumer Response process.

2024-MO-C-016 12 of 25

Select Consumer Response processes

Actions taken by Consumer Response

GPRA performance goal

Consumer Response’s GPRA performance goal for 2021

and 2022 was to review the response performance of

85 percent of companies with more than 250 complaints.

The goal for 2019 was 82 percent and for 2020,

83 percent.

We reviewed the CFPB’s annual performance plans and

reports and the Investigations section’s company

monitoring data from 2019 through 2022. We found

that Consumer Response met its GPRA performance

goal by reviewing the response performance of at least

85 percent of companies with more than 250 annual

complaints.

Sampling company responses

According to Consumer Response’s Company Monitoring

Directive, company monitoring teams use a random

sample of consumer complaints to review selected

company responses.

We reviewed 40 company monitoring teams’ company

scorecards from 2019 through 2022 and conducted a

walk-through with Consumer Response officials to

confirm the use of a random sample of complaints. We

found that Consumer Response followed its procedures

for sampling consumer complaints from selected

companies.

QA reviews

According to the Investigations section’s Investigations

Quality Assurance Directive, the QA team reviews the

company monitoring teams’ completed assessment

questionnaires to ensure that they reflect comprehensive

and accurate analyses and are conducted in accordance

with procedures.

We reviewed QA reports from eight monthly periods

from 2019 through 2022. We found that Consumer

Response followed its procedures for conducting QA

reviews of the company monitoring teams’ completed

assessment questionnaires, including documenting

QA’s analyses and reasons for disagreements with

determinations made in the assessment questionnaires

and identifying potential deviations from Consumer

Response’s procedures.

Source: OIG analysis of Consumer Response datasets for 2019–2022 and interviews with Consumer Response officials.

For 2022, Consumer Response deviated from its process to create its company review schedule by using data fields that

differed immaterially from those outlined in its Company Monitoring Directive.

Management Response

In response to our draft report, the associate director of consumer response and education states that he

is pleased that the audit found that the office generally followed its processes for reviewing and

monitoring company responses to consumer complaints.

2024-MO-C-016 13 of 25

Finding 2: Consumer Response Should

Ensure Consistent Documentation of

Company Response Performance

Consumer Response’s company monitoring teams generally followed procedures for documenting their

review of company responses to consumer complaints in assessment questionnaires; however, we found

that the teams did not consistently complete one specific required field of the assessment questionnaire.

Consumer Response’s procedures specify that company monitoring teams must use the determination

finding field when documenting their review. In addition, the U.S. Government Accountability Office’s

(GAO) Standards for Internal Control in the Federal Government highlights the importance of application

controls, such as system controls, which are incorporated directly into computer systems to ensure the

completeness of data. According to Consumer Response, the determination finding field is not a

mandatory field in the complaint management system. During our fieldwork, Consumer Response

informed us of its plans to implement a system change that would make the determination finding field

mandatory. Developing system controls for all required fields would help to ensure the consistent

completion of company response performance assessment questionnaires, which would give Consumer

Response a clear picture of how companies are responding to consumer complaints.

Consumer Response Should Develop System

Controls for All Required Fields

Consumer Response generally has controls to prevent company monitoring teams from submitting

incomplete assessment questionnaires. We found, however, that company monitoring teams did not

consistently document their review in the determination finding field of the assessment questionnaire.

According to Consumer Response’s Company Monitoring CRI (Consumer Response Investigation) User

Support Tool, company monitoring teams must use the determination finding field to document (1) a brief

synopsis of the consumer complaint and company response and (2) an explanation as to why any

responses were deemed to be unsatisfactory. Further, the GAO’s Standards for Internal Control in the

Federal Government highlights the importance of application controls, such as system controls, which are

incorporated directly into computer systems to ensure the completeness of data.

According to Consumer Response, the determination finding field is not a mandatory field within

Consumer Response’s internal complaint management system, and some company monitoring staff use

the complaint specific finding field instead of the determination finding field in the assessment

questionnaire.

As a result, 9,360 of the 143,742 (6.5 percent) assessment questionnaires completed

from 2019 through 2022 had incomplete determination finding fields.

The complaint specific finding field is an optional field designed to highlight common issues and identify trends.

2024-MO-C-016 14 of 25

Updating system controls to make all required assessment questionnaire fields mandatory will help to

ensure that Consumer Response completely and consistently documents its company response

performance assessments. Complete assessments will give Consumer Response a clear picture of how

companies are responding to consumer complaints.

Management Actions

After our preliminary findings meeting, Consumer Response implemented a change to its complaint

management system. The determination finding field is now a mandatory field in the system and must be

completed before the assessment questionnaire can be saved. Based on our review of documentation

evidencing this change, we are not making a recommendation to address this item.

Management Response

In response to our draft report, the associate director of consumer response and education states that he

is pleased with our audit’s recognition of the office’s efforts to implement a system change to make the

determination finding field mandatory and of the office’s commitment to maintaining proper controls to

ensure the completeness of the data.

2024-MO-C-016 15 of 25

Finding 3: Consumer Response Can

Strengthen Its Processes for Issuing

Company-Specific Reports on Response

Performance

Consumer Response’s pilot process to issue discretionary company-specific reports lacked measurable

objectives, a pilot completion date, and formal written guidance for selecting certain companies to

receive company-specific reports. In addition, Consumer Response did not have a process to periodically

evaluate the effectiveness of its pilot process. GAO’s Standards for Internal Control in the Federal

Government emphasizes the need for establishing policies and procedures and highlights the importance

of periodically reviewing processes for their effectiveness in achieving objectives. Instead of establishing

formal objectives and documenting its process for issuing company-specific reports, Consumer Response

developed informal guiding principles that can vary year to year. Finalizing objectives, conducting periodic

monitoring, and establishing a completion date for the pilot process will help Consumer Response

effectively assess the value of the process and identify potential improvements. In addition, developing

formal guidance for issuing company-specific reports will help Consumer Response establish a repeatable

process.

Consumer Response Should Finalize Measurable

Objectives, Establish Formal Written Guidance,

and Periodically Evaluate Its Company-Specific

Reports Issuance Pilot Process

In 2021, Consumer Response initiated a pilot process to share company-specific reports on response

performance with a limited number of companies.

We found that Consumer Response’s pilot process

lacked measurable objectives and a completion date. Further, Consumer Response did not develop

formal written guidance for its company selection process. For example, in 2021 and 2022, we could not

determine why some companies were chosen to receive reports and others were not. In addition,

Consumer Response did not have a procedure to periodically evaluate the effectiveness of its pilot

process against measurable objectives.

GAO’s Standards for Internal Control in the Federal Government sets internal control standards for federal

entities and outlines the importance of establishing and maintaining effective internal control activities

through policies and procedures. In addition, it states that federal entities should periodically review

policies, procedures, and related control activities for their relevance and effectiveness in achieving

objectives and addressing risks.

Consumer Response issued 12 company-specific reports in 2021 and 22 in 2022.

2024-MO-C-016 16 of 25

A Consumer Response official informed us that the office did not establish formal objectives to allow for

flexibility within the report issuance process. In addition, Consumer Response did not develop formal

guidance for selecting companies to receive company-specific reports, and instead developed informal

guiding principles. According to a Consumer Response official, the informal guiding principles for issuing

company-specific reports can vary year to year.

Because Consumer Response did not establish specific parameters for its pilot process, certain

components of the pilot process changed over time. For example, although our audit review period did

not include Consumer Response’s processes in 2023, Consumer Response informed us that in 2023 its

approach for issuing company-specific reports evolved to begin distributing such reports to

nondepository institutions as well as continuing to employ risk-based prioritization for the sharing of such

reports with companies.

Finalizing measurable objectives for the pilot process, conducting periodic monitoring, and establishing a

specific duration for the pilot process can help Consumer Response assess the lessons learned from the

pilot and determine whether to implement the process more permanently. In addition, developing formal

guidance for issuing company-specific reports, including identifying which companies receive them, will

help Consumer Response establish a repeatable process.

Recommendations

We recommend that the associate director of consumer response and education

1. Finalize measurable objectives and establish a completion date for the company-specific reports

pilot process.

2. Establish written guidance for issuing company-specific reports.

3. Periodically monitor the company-specific reports pilot process to measure its effectiveness in

improving company responsiveness.

Management Response

In response to our draft report, the associate director of consumer response and education concurs with

our recommendations. Specifically, regarding recommendation 1, the response states that Consumer

Response has begun to finalize the pilot process, including specifying a completion date and defining

measurable objectives; the office plans to finalize the pilot process by the second quarter of fiscal year

2025.

Regarding recommendation 2, the response states that Consumer Response has prepared a formal

procedure for issuing company-specific reports and plans to finalize the procedure by the second quarter

of fiscal year 2025.

Regarding recommendation 3, the responses notes that Consumer Response has started taking steps to

monitor and measure the company-specific reports pilot process by developing a dashboard and plans to

finalize the dashboard by the second quarter of fiscal year 2025.

2024-MO-C-016 17 of 25

OIG Comment

The planned actions described by the associate director of consumer response and education appear to

be responsive to our recommendations. We will follow up to ensure that the recommendations are fully

addressed.

2024-MO-C-016 18 of 25

Appendix A: Scope and Methodology

Our audit objective was to assess the effectiveness of Consumer Response’s processes for reviewing and

monitoring the timeliness, accuracy, and completeness of company responses to consumer complaints in

accordance with its established directives and procedures.

To accomplish our objective, we reviewed Consumer Response’s directives and procedures for reviewing

and monitoring company responses to consumer complaints. We interviewed Consumer Response

officials to obtain an understanding of the office’s company monitoring processes. We also reviewed and

analyzed Consumer Response’s company monitoring data from January 1, 2019, to December 31, 2022.

We assessed the reliability of Consumer Response’s company monitoring data by reviewing existing

information about the data and the system that produced them, interviewing CFPB officials

knowledgeable about the data, and conducting a walk-through of certain data processes. We determined

that the data were sufficiently reliable for the purposes of this report.

Using information obtained during interviews with Consumer Response officials and our review of

Consumer Response’s directives and procedures, we identified select Consumer Response processes for

review to assess the effectiveness of Consumer Response’s company response monitoring. Specifically,

• examined Consumer Response’s annual company review schedules from 2019 through 2022 to

determine whether Consumer Response followed procedures for analyzing company complaint

data, selecting companies for review, and creating company review schedules

• reviewed Consumer Response’s GPRA performance goal and company monitoring data to verify

that all companies that received 250 or more annual complaints from 2019 through 2022 were

reviewed

• reviewed a nonstatistical sample of 40 company scorecards for companies reviewed by company

monitoring teams from 2019 through 2022 to ensure that Consumer Response followed

procedures for sampling company responses

• analyzed all assessment questionnaires completed by Consumer Response’s company monitoring

teams from 2019 through 2022 to verify that all fields were completed in accordance with

procedures

• reviewed a nonstatistical sample of eight monthly QA reviews of completed assessment

questionnaires from 2019 through 2022 to determine whether Consumer Response completed

QA reviews according to procedures

• reviewed Consumer Response’s notification process for issuing company-specific reports to

companies in 2021 and 2022 to determine whether Consumer Response had procedures to guide

its process for identifying and issuing reports to companies

We conducted this performance audit in accordance with generally accepted government auditing

standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate

evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We

2024-MO-C-016 19 of 25

believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on

our audit objectives. We conducted this work from May 2023 to May 2024.

2024-MO-C-016 20 of 25

Appendix B: Management Response

2024-MO-C-016 21 of 25

2024-MO-C-016 22 of 25

2024-MO-C-016 23 of 25

2024-MO-C-016 24 of 25

Abbreviations

GAO

Government Accountability Office

GPRA

Government Performance and Results Act Modernization Act

Quality Assurance

2024-MO-C-016 25 of 25

Report Contributors

Brian Maloney, Project Lead

Katrina Jenkins, Auditor

Laura King, Auditor

Andrew Luckman, Forensic Auditor

Nick Stefaniak, Forensic Auditor

Lindsay S. Mough, OIG Manager, Management and Operations

Victor Calderon, OIG Manager for Data Analytics

Andrew Gibson III, Senior OIG Manager for Management and Operations

Cynthia Gray, Deputy Associate Inspector General for Audits and Evaluations

Michael VanHuysen, Associate Inspector General for Audits and Evaluations

Contact Information

General

Office of Inspector General

Board of Governors of the Federal Reserve System

20th Street and Constitution Avenue NW

Mail Center I-2322

Washington, DC 20551

Phone: 202-973-5000

Fax: 202-973-5044

Media and Congressional

OIG.Media@frb.gov

OIG Hotline

Hotline

Report fraud, waste, and abuse.

Those suspecting possible

wrongdoing may contact the

OIG Hotline by mail,

web form, phone, or fax.

OIG Hotline

Board of Governors of the Federal Reserve System

20th Street and Constitution Avenue NW

Mail Center I-2322

Washington, DC 20551

Phone: 800-827-3340

Fax: 202-973-5044